What will veterinarians say about FDA’s Compliance Policies?
Most veterinarians are unaware of FDA Compliance Policies that openly allow illegal wastes into pet food. So…how about we provide our veterinarians with the evidence this waste is allowed and commonly used in pet food and ask our vets to stand with us? Perhaps it is our job to begin to provide regulatory education to our veterinarians, and ask them to send the FDA an opinion this material is NOT safe in pet food.
The Let’s Ask Our Veterinarians Mission:
(cue dramatic music)
Step 1. Pet owners provide veterinarians with copies of FDA Compliance Policies.
Step 2. We ask our veterinarians to give us their opinion on this FDA allowed waste in pet food.
Step 3. We ask our veterinarian to email FDA their opinion. AskCVM@fda.hhs.gov
The FDA ignores consumer concerns about pet food, but will the agency ignore veterinarians? Even if FDA chooses to ignore concerns of veterinarians, pet owners win because we’ve shared valuable pet food education with our vets.
Background for you and your veterinarian:
Federal law defines food as: “(f) The term “food” means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article.”
Federal law defines an adulterated food as (in part): “(5) if it is, in whole or in part, the product of a diseased animal or of an animal which has died otherwise than by slaughter.”
The laws quoted above are from the Federal Food, Drug and Cosmetic Act, which FDA is charged with enforcing (see Laws Enforced by FDA).
Three questions for your veterinarian…
#1 Ask your veterinarian: Do you believe pet food should abide by federal law?
Of course your veterinarian will agree that pet food should abide by federal laws. But, probably what your vet doesn’t know is that FDA allows pet food to violate federal law through their use of Compliance Policies. The next part of your mission is to explain to your veterinarian what Compliance Policies are…
The FDA website explains Compliance Policies as: “Compliance Policy Guides (CPGs) explain Food and Drug Administration (FDA) policy on regulatory issues related to FDA laws or regulations.”
In “Chapter 6 – Veterinary Medicine” of FDA Compliance Policy Guides, “Sub Chapter 660 – 699 Animal Food” we find the following two examples of FDA ignoring law in pet food which can be printed or emailed to your vet:
Example #1: CPG Sec. 690.300 Canned Pet Food. This FDA policy states: “POLICY: Pet food consisting of material from diseased animals or animals which have died otherwise than by slaughter, which is in violation of 402(a)(5) will not ordinarily be actionable, if it is not otherwise in violation of the law. It will be considered fit for animal consumption.”
In the above FDA pet food policy, FDA admits this material is “in violation” of the Federal Food Drug and Cosmetic Act (402 (a)(5) quoted above). But, completely ignoring federal law (actually, this FDA policy is word for word OPPOSITE of law) the agency states – “material from diseased animals or animals which have died otherwise than by slaughter“…”will be considered fit for animal consumption.” Pet owners can print the above Compliance Policy to deliver to your vet, or email the link.
Ask your veterinarian: Is material from diseased animals or animals which have died otherwise than by slaughter fit for my pet’s consumption?
If your vet agrees with FDA’s position (this material is fit for animal consumption), ask them to explain why they believe it is safe. If they say no, ask your vet why they believe this material is not safe for pets to consume. And then ask your veterinarian to take a stance with you; ask your vet to share their opinion with FDA by sending a brief (or lengthy) email to FDA at
Example #2: CPG Sec. 675.400 Rendered Animal Feed Ingredients. This FDA policy states: “POLICY: No regulatory action will be considered for animal feed ingredients resulting from the ordinary rendering process of industry, including those using animals which have died otherwise than by slaughter, provided they are not otherwise in violation of the law.”
Ask your veterinarian: Is rendered pet food ingredients sourced from animals which have died otherwise than by slaughter a safe, quality ingredient?
If your veterinarian disagrees with FDA’s position of ignoring federal law allowing waste in pet food, thank them for their opinion and (again) ask them to share that opinion with FDA.
Just maybe…we can get our veterinarians to stand with us against FDA’s allowance of illegal pet foods! Maybe when our vets learn what really goes into pet food, everything can change.
Wishing you and your pet(s) the best,
Become a member of our pet food consumer Association. Association for Truth in Pet Food is a a stakeholder organization representing the voice of pet food consumers at AAFCO and with FDA. Your membership helps representatives attend meetings and voice consumer concerns with regulatory authorities. Click Here to learn more.
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